Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Deemed dividend - only the assessee is holding 15% of the voting power in the lending company and 45% of voting power in the borrowing company - there is no question of any proportionate addition when the assessee is the only share holder who fulfills the condition prescribed u/s 2(22)(e) - AT
Deemed dividend - only the assessee is holding 15% of the voting power in the lending company and 45% of voting power in the borrowing company - there is no question of any proportionate addition when the assessee is the only share holder who fulfills the condition prescribed u/s 2(22)(e) - AT
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